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City of London Corporation
Local Flood Risk Management Strategy
2014 - 2020
Sept 2014
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Contents 1 Introduction ....................................................................................................................... 4
2 Flood Risk Management Strategy requirements ......................................................... 6
3 Assessment of local flood risks ........................................................................................ 7
3.1 Flood risk modelling .................................................................................................. 7
3.2 River and tidal flood risk ........................................................................................... 7
3.3 Surface water and sewer flood risk ........................................................................ 8
3.4 Ground water flood risk.......................................................................................... 11
3.5 Climate change and flood risk ............................................................................. 12
3.6 Strategic Flood Risk Assessment and Flood Risk Maps ....................................... 13
4 Objectives for Managing Flood Risk in the City ......................................................... 14
4.1 Objective 1: Flood Risk Information ...................................................................... 15
4.2 Objective 2: Reduced vulnerability and cost of flooding ................................ 16
4.2.1 Planning ............................................................................................................ 16
4.2.2 Flood resistance and resilience ..................................................................... 17
4.2.3 Flood Insurance ............................................................................................... 18
4.2.4 SuDS approvals ................................................................................................ 19
4.2.5 Asset register .................................................................................................... 19
4.2.6 Flood investigation .......................................................................................... 20
4.2.7 Warning and Informing ................................................................................... 20
4.2.8 Site Specific Flood Risk Management Plans ................................................ 21
4.3 Objective 3: Emergency response to flooding ................................................... 22
4.4 Objective 4: Recovery from flooding................................................................... 23
4.5 Objective 5: Partnership working .......................................................................... 24
4.5.1 Drain London .................................................................................................... 24
4.5.2 Environment Agency ...................................................................................... 24
4.5.3 Port of London Authority ................................................................................. 25
4.5.4 Neighbouring boroughs.................................................................................. 25
4.5.5 Regional Flood and Coastal Committee ..................................................... 26
4.5.6 Utility providers ................................................................................................ 26
4.5.7 Transport providers .......................................................................................... 26
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4.5.8 Technical bodies and Associations............................................................... 27
4.5.9 Emergency Services ........................................................................................ 27
5 Actions to reduce flood risk in the City ....................................................................... 28
5.1 Measures to achieve objectives .......................................................................... 28
5.2 Site Specific Flood Risk Management Plans ........................................................ 28
5.3 Funding & Resources .............................................................................................. 29
5.4 Flood Risk Action Plan ............................................................................................ 30
6 Strategy review ............................................................................................................... 38
6.1 Public Consultation ................................................................................................. 38
6.2 Approval process .................................................................................................... 38
6.3 Governance and monitoring ................................................................................ 38
6.4 Review ...................................................................................................................... 38
7 Wider sustainability objectives ..................................................................................... 39
7.1 Strategic Environmental Assessment .................................................................... 39
7.2 Overall SEA conclusion .......................................................................................... 41
Appendix 1 Legislative context ........................................................................................... 42
Appendix 2 Flood Risk Powers and Responsibilities .......................................................... 48
Glossary ................................................................................................................................... 50
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1 Introduction The City is at relatively low risk of flooding with specific areas at some risk from
river flooding and surface water/sewer flooding (Fig 1). However the consequences
of flooding in these restricted parts of the City could be very high in terms of
disruption to business, inconvenience to occupiers and reputational damage.
Figure 1: Flood Risk in the City of London
The City‘s flood risks must be considered strategically since flood risks are
associated with river catchments which extend well beyond the City‘s boundaries.
Changing weather patterns as a result of climate change will also influence the
City‘s future probability of flooding with more intense rainfall events creating
conditions where flash flooding and overloading of the sewer network could
become more frequent. Sea level rise will increase the risk of flooding from the tidal
Thames in future decades. As a consequence past experience of flooding is not
necessarily an accurate predictor of future flood risk.
The City is protected from River flooding by the Thames Barrier and by local
flood defences along the riverside. The Thames Estuary 2100 Plan (TE2100 plan)
identifies the wider actions which are needed to protect London from future
flooding, some of which will need to be implemented within the City. Surface
water/sewer flooding is a risk along Farringdon Street and the Thames riverside as a
result of rainwater catchments as far afield as Hammersmith to the west and
Hampstead to the north of the City. It is impossible to completely eliminate the
possibility of flooding therefore an important element of flood preparedness is the
implementation of measures to provide resistance, preventing flood waters entering
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properties and flood resilience enabling rapid recovery in the event of flooding.
Emergency planning provides the assurance that in the event of flooding
procedures are in place to respond effectively.
This strategy identifies the approach the City Corporation is taking to the flood risks
that affect the City, the actions that are underway or planned to reduce these risks
and the processes by which this strategy will be kept up to date.
The Flood and Water Management Act 2010 assigns various responsibilities to Lead
Local Flood Authorities including the requirement to develop, maintain apply and
monitor a strategy for local flood risk management in its area. The City Corporation,
as unitary authority for the Square Mile is the Lead Local Flood Authority for the City.
This strategy covers flood risk affecting the City‘s geographic area; it does not
include flood risks on City owned or managed land beyond the City‘s boundaries.
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2 Flood Risk Management Strategy requirements The Flood and Water Management Act 2010 specifies the Lead Local Flood
Authority‘s duties with regard to Local Flood Risk Management Strategies and
outlines the elements that must be included in a Flood Risk Management Strategy.
Table 1 shows these requirements and where each one is covered in the City of
London Local Flood Risk Management Strategy.
Table 1: Flood and Water Management Act 2010 section 9 (4) Strategy Requirements
The Flood and Water Management Act 2010 section 9 (4)
requires that the strategy must specify:
Where it is covered
in this strategy
(a) the risk management authorities in the authority's area, Appendix 2
(b) the flood and coastal erosion risk management
functions that may be exercised by those authorities in
relation to the area,
Appendix 2
(c) the objectives for managing local flood risk (including
any objectives included in the authority's flood risk
management plan prepared in accordance with the
Flood Risk Regulations 2009),
Chapter 4
(d) the measures proposed to achieve those objectives, Chapter 4 and
Chapter 5
(e) how and when the measures are expected to be
implemented,
Chapter 5
(f) the costs and benefits of those measures, and how they
are to be paid for,
Chapter 5
(g) the assessment of local flood risk for the purpose of the
strategy,
Chapter 3
(h) how and when the strategy is to be reviewed, and Chapter 6
(i) how the strategy contributes to the achievement of
wider environmental objectives.
Chapter 7
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3 Assessment of local flood risks Signpost to the Flood and Water Management Act 2010 Section 9 (4) requirements
This section deals with
(4)(g) the assessment of local flood risk for the purpose of the strategy
3.1 Flood risk modelling
Historically the City has not experienced significant flooding since 1928 when an
area around Blackfriars was subject to flooding. The exact cause of this flooding is
not known but it is likely to have been as a result of localised breach or overtopping
of the flood defence wall or overloading of the sewer system following inundation
elsewhere in London. Due to the City‘s economic importance large scale flood
defences have provided protection in the intervening years. However climate
change is affecting weather patterns resulting in greater risk of flooding, and the
paving over of areas which previously absorbed rainwater run-off has resulted in
altered flood risk compared with previous decades. In order to predict the future risk
of flooding computer modelling has been carried out by the Environment Agency
with respect to river and tidal flooding and by Halcrow on behalf of the City
Corporation for ground water, surface water and sewer flooding. The City of London
Strategic Flood Risk Assessment provides details of this modelling and is the primary
source of evidence of the future City flooding risks. It should be noted that modelling
provides the best prediction of how flooding may affect the City but monitoring and
investigation will improve the accuracy of this data.
3.2 River and tidal flood risk
The City of London 2012 Strategic Flood Risk Assessment (SFRA) shows that
limited areas of the City are at risk from river flooding in the absence of any flood
defences. The risk is confined to the riverside south of Thames Street and the Temples
area (Fig 2). In reality the City is protected from river flooding by local flood
defences along the riverside and by the Thames Barrier which protects the wider
tidal Thames from flooding. Future flood risk from the Thames has been analysed
through the Thames Estuary 2100 project which proposes various actions to reduce
future risk, taking account of the impacts of climate change including sea level rise.
Estuary wide actions promote the approach of making space for flood waters in
flood plains along the estuary as opposed to flood defence raising. However in
central London the opportunities for absorbing tidal flood waters into the landscape
are limited therefore local actions in the City include the need to raise the flood
defence walls by up to 0.5 metres by 2065 and a further 0.5m by 2100.
The Environment Agency has undertaken Breach Modelling (2012) which
assesses the residual risk of a breach or overtopping of the flood defences at certain
locations along the river. There is a breach location modelled in the City of
Westminster close to the City boundary, which shows that the modelled breach
extends into the Inner Temple area of the City of London. This breach modelling will
be updated in 2014/15 to account for new TE 2100 modelled levels.
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Figure 2 Areas at risk of river flooding
3.3 Surface water and sewer flood risk
The risk of flooding from surface water and sewer overflow is also confined to
restricted areas of the City including the former Fleet Valley at Farringdon Street and
the Thames Riverside (fig 3). This flooding is caused by overloading of the combined
drainage and sewer network resulting in overflows from manholes in these areas. The
use of Sustainable Drainage Systems in buildings and landscaping assists in reducing
the rate at which surface water enters the sewer network thus reducing surface
water flood risk.
Example of local actions to reduce surface water flood risk
The City‘s Open Spaces Department supports this corporate strategy by
making sure paving in the City‘s gardens drains to natural ground, for example by
using soak-aways, rather than to the piped City drainage system. Trees and other
planting, the use of green roofs and green walls are also assisting in flood risk
reduction, where appropriate.
Given the density of the buildings and development in the City, building
rainwater harvesting is encouraged through the planning process. An example is the
harvesting of rainwater as part of the redevelopment of 10 Trinity Square to irrigate
Seething Lane Garden
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Figure 3: Surface water and sewer flooding zones
The sewers that serve this area have wide catchments extending throughout
Camden to the north (Fig 4) and as far as Hammersmith and Fulham to the west (Fig
5); therefore local engineering action within the City of London to reduce the risk is
unlikely to be effective in isolation. The actions to alleviate flood risk in these areas
extend across a wide area and include installation of Sustainable Drainage Systems
(SuDS) across the drainage catchment and maintenance and improvement of the
Thames Estuary wide flood defences. These actions form part of a wider strategy
within the surface water catchment. Measures to alleviate flood risk will also have
other benefits for water resource management through rainwater harvesting and
reuse; and for water quality through reducing the level of rainwater entering the
drainage network thus reducing the potential for sewer discharges.
Example of a wider action which reduces flood risk in the City.
The surface water catchment areas for the City‘s flood risk hotspots extend to
the edge of Hampstead Heath (Figs 4 & 5). The City Corporation is planning works to
ensure that the pond dams on Hampstead Heath do not fail or cause flooding in the
local area following a major rainfall event. Any such protection from flood risk in the
Hampstead Heath area provides consequential benefits in reducing the risk of sewer
overflows elsewhere in this catchment area, including the flood risk hotspots in the
City.
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Figure 4: Catchment area for flood risk in Farringdon Street
Figure 5: Catchment area for flood risk in the Paul's Walk area
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3.4 Ground water flood risk
The City is protected from ground water flooding by the GARDIT programme which
maintains groundwater levels in the deep chalk aquifer at between -30 and -50 m
AOD. The City may also be vulnerable to groundwater flooding from the shallow
aquifer which comprises sand and gravel with high porosity and permeability. The
areas of the City which are most at risk from groundwater flooding from this shallow
aquifer are shown in Fig 6: Areas with increased potential for elevated groundwater.
Complex interactions between rainfall infiltration, basement barriers and the
predominance of impermeable surfaces in the City, makes this type of flood risk
difficult to predict, however flooding from this source is not thought to be likely in the
short to medium term. Longer term impacts of climate change on ground water
flood risk are less certain.
Figure 6: Areas with increased potential for elevated groundwater
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3.5 Climate change and flood risk
Our climate is changing and is likely to continue to change for many decades to
come. The City of London Climate Change Adaptation Strategy (2010) identifies the
expected changes that London will face, which include an increasing magnitude
and frequency of intense rainfall events.
Flooding is a natural process and the speed of inundation and duration varies
greatly. With climate change, however, the frequency, velocity, depth, patterns and
severity of flooding are forecast to increase causing flash flooding, and heavier
average winter precipitation that will put us at greater risk of flooding.
The City of London Climate Change Adaptation Strategy (2010) is based on the UK
Climate Projections 2009 (UKCP09). These scenarios are generated with probabilistic
data. No climate model can give a single definite answer to what the future will
look like, however, under the high emissions scenario peak rainfall is likely to increase
significantly.
In the figure below, the black line shows the central estimate (50th percentile) of the
increase in precipitation on the wettest winter day for the high emissions scenario.
The wide grey bars show the likely range of change (33rd to 66th percentiles). The
error bars show the 10th and 90th percentile events (future increase in precipitation
on the wettest winter day is very unlikely to be outside this range).
Figure 7: Future rainfall as a result of climate change (Source: City of London Climate Change Adaptation Strategy)
It is clear that unless action is taken, flood risks in the City of London will increase.
Climate change is increasing the magnitude and frequency of intense rainfall
events that cause flash flooding. According to the London Local Climate Impacts
Profile (LCLIP) published by the Greater London Authority (GLA) heavy rain and flash
flooding were the most frequently occurring weather incidents reported in the
media, with cases of river flooding also being reported. Existing problems have also
been identified within the City. For example, the existing drainage system at the
Guildhall Art Gallery cannot cope with intense rainfall at times, and this has led to
some flooding of its basement, damage and associated cost.
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3.6 Strategic Flood Risk Assessment and Flood Risk Maps
The City of London Strategic Flood Risk Assessment (SFRA) (2012) provides the results
of the latest flood risk modeling and mapping for the City. Neighbouring boroughs‘
SFRAs and Local Flood Risk Management Strategies provide further evidence of the
risks elsewhere in London which may affect the City. The Environment Agency
publish various flood maps for coastal and river flooding, flood maps for surface
water and reservoir flood maps which give a wider perspective. However the SFRA
modelling carried out for the City reflects the most accurate picture for the Square
Mile and has been incorporated into the Environment Agency Maps.
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4 Objectives for Managing Flood Risk in the City Signpost to the Flood and Water Management Act 2010 Section 9 (4) requirements
This section deals with
(c) the objectives for managing local flood risk (including any objectives included in
the authority's flood risk management plan prepared in accordance with the Flood
Risk Regulations 2009),
The following objectives for managing local flood risk aim to reduce the risk and
impact of flooding on the City:
To provide up to date information regarding the level of flood risk within the
City taking account of emerging climate change impacts
To reduce the vulnerability and cost to City businesses, residents and visitors of
flood risk
To respond effectively in the event of flooding providing emergency
assistance to those in need
To assist in recovery enabling the City residents and businesses to resume
normal activities promptly
To engage with other flood risk management authorities taking action to
reduce flood risk through partnership working within and beyond the City‘s
boundaries
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4.1 Objective 1: Flood Risk Information
To provide up to date information regarding the level of flood risk within the City
taking account of emerging climate change impacts
City of London SFRA 2012
In 2007 the City Corporation published its first Strategic Flood Risk Assessment
which was updated in 2012. The City of London Strategic Flood Risk Assessment
(SFRA) 2012 provides information on the flood risks the City faces from fluvial and
tidal, surface water, sewer overflows and groundwater. The SFRA 2012 brings
together evidence from the City of London SFRA 2007, Drain London Surface Water
Management Plan and Preliminary Flood Risk Assessment. New modelling has been
undertaken, taking account of the drainage and sewer network thereby providing
an up to date assessment of the potential risks from surface water and sewer
overflows.
Flood Maps for Surface Water (FMfSW)
The Environment Agency (EA) has a duty to publish flood risk and flood hazard
mapping for the whole of London which has been identified as a Flood Risk Area
under the Flood Risk Regulations 2009. The City Corporation has commissioned more
detailed modelling than the EA for the City and this data has been supplied for
incorporation into the Flood Map for Surface Water (FMfSW) thus providing the most
up to date information on flood risk for the City. The City Corporation will engage
with the EA to ensure that future reviews of the FMfSW continue to include the most
up to date mapping and modelling, including any future predicted impacts of
climate change.
What we will do:
We will review the City of London SFRA at least every 5 years or more
frequently if evidence suggests that this is necessary. This frequency of review
will enable the impacts of climate change to be taken into account as
evidence emerges.
We will keep under review the SFRAs and flood risk modelling that is carried
out for neighbouring boroughs through the Central London North Flood Risk
Partnership
Where feasible, we will provide the most up to date mapping and modelling
to the EA for incorporation in future reviews of the FMfSW
We will continue to engage with other risk management authorities and other
interested parties to improve data on flood risk for the City
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4.2 Objective 2: Reduced vulnerability and cost of flooding
To reduce the vulnerability and cost to City businesses, residents and visitors of flood
risk
4.2.1 Planning
New development provides an opportunity to review existing flood risk potential for
each site and ensure that future use of the site reduces the vulnerability of
occupants to flooding and provides flood protection for a wider area where
possible. The National Planning Practice Guidance identifies which land uses are
suitable for sites that are at risk of flooding. The City Corporation applies this
guidance in order to avoid locating vulnerable uses, such as basement dwellings or
essential infrastructure, in areas that are at risk of flooding. The City of London Local
Plan defines the City Flood Risk Area as the area of the City which is susceptible to
flooding from the River Thames, surface water or the sewer network. The National
Planning Practice Guidance will be applied to development within this City Flood
Risk Area.
The City Corporation encourages the use of green roofs and green walls as they
reduce or delay the amount of water discharged into the drainage system (along
with rainwater attenuation tanks and other methods). We encourage developers of
new developments to install green roofs and green walls and to retrofit them in
refurbishments. Case studies of properties with green roofs within the City are
available on the City of London website to promote their use.
The City of London Climate Change Adaptation Strategy, which is available to the
public on the City of London website, identifies the priority risks associated with
climate change and proposes adaptation measures. These are designed to ensure
the City‘s infrastructure and services cope under a changing climate. The report
identifies specific risks and opportunities associated with managing flood risk. The
Thames Estuary 2100 plan recommends that flood defence raising will be required to
take account of sea level rise by 2065. Development that is being planned now may
still be in place beyond 2065 and should be designed to factor in these higher flood
defences which otherwise could obscure views of the river.
The riverside walk in the City forms part of the Thames Path National Trail. This will
need to be taken into consideration when any works are ongoing which could
potentially affect its use. There are strict guidelines around diversions and any closure
requires Secretary of State approval.
What we will do:
Apply the National Planning Policy Framework (NPPF) and associated
National Planning Practice Guidance on flood risk, developing and
implementing flood risk policy in the Local Plan which accords with the
Sequential and Exceptions Tests.
Implement planning policy to avoid the development of vulnerable uses in
City Flood Risk Areas as defined on the City of London Local Plan Policies Map
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Require the use of green roofs and green walls and other urban drainage
techniques in new development and encourage use in existing buildings to
improve flood resilience subject to impacts on heritage value.
Highlight the need for future raising of flood defences along the riverside to
developers of property in this area, encouraging a strategic approach to
local flood defences.
Use pre-application meetings to promote flood resistance and resilience
measures to property owners considering refurbishment or redevelopment in
the City Flood Risk Area.
4.2.2 Flood resistance and resilience
The City Corporation has established a corporate-wide officer Flood Risk Steering
Group, enabling joint and integrated working across Departments. This integrated
approach ensures that new developments within the City are flood resistant and
resilient, and that existing properties including heritage assets improve their resilience
to flooding without damage to their design or heritage value.
Flood resistance is the process of preventing flood waters from entering buildings
and spaces. The City‘s buildings and spaces differ from those in other parts of
London because of the predominance of office buildings.
Flood resilience is the process of designing buildings and spaces so that if flooding
occurs it creates minimal damage and enables rapid recovery.
The City Corporation have used Drain London funding to improve flood resistance
and resilience working with City businesses, residents and different departments
within the City of London Corporation to reduce the vulnerability and raise
awareness of surface water flooding in the City. There are several stages to this
flood resistance and resilience programme which have been completed::
the development of evidence-based responses to reduce risk
without increasing flood risk elsewhere;
the development of online resources available on the City of
London website;
the creation of case studies and development of
recovery/resilience advice; and
the production of a Flood Risk Briefing for flood risk authorities,
building owners and occupiers to attend with presentations from
the EA, Met Office and a local business.
We will continue to:
identify and co-operate with key stakeholders;
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educate and raise an awareness of flood risk in the City;
develop a planning advice note on flood resistance and resilience
to be factored into future planning permissions;
identify secondary benefits for biodiversity and urban greening of
flood resistance and resilience measures
All of these actions will improve the overall understanding of flooding in the City and
assist in recovery enabling normal activities to be resumed promptly.
What we will do
Promote flood resistance and resilience measures to property owners in the
City Flood Risk Area ensuring that the heritage implications of mitigation
measures are taken into account
Work to ensure all City Corporation infrastructure is resistant and resilient to
flood risk, such as the Waste Transfer Station at Walbrook Wharf
Seek funding contributions from those who will benefit from any collective
flood resistance and resilience measures
4.2.3 Flood Insurance
Property insurance claims for flood damage across the UK have increased
significantly over recent years and are set to increase further due to the impacts of
climate change. Since 2000 flood insurers have been providing cover under a
―Statement of Principles‖ agreement with the government which ensures that flood
insurance is available to householders and small and medium sized enterprises
(SMEs). Large commercial properties are not covered by the Statement of Principles
and therefore need to arrange for flood risk insurance at market rates. The
Statement of Principles expired in June 2013.
The Government‘s preferred option for ensuring that flood insurance is available to
householders in the future is the proposed ―Flood RE‖ scheme. Flood RE would
provide a reinsurance fund, through a levy on the insurance industry, to provide
insurance cover for residential properties which would otherwise be uneconomic to
insure due to flood risk. Flood RE would provide fixed price flood insurance to be
reviewed annually. Parliamentary approval through the Water Bill will put in place
the legislation for this scheme to be implemented. Final implementation is likely to be
in summer 2015. In the meantime the insurance industry has voluntarily agreed to
continue providing cover under the Statement of Principles. The Flood RE scheme is
intended to be a transitional scheme which would gradually evolve over the next 25
years at which time a free market for all flood risk insurance would take over.
There are very few residential properties in the City which are at risk of flooding;
consequently the Flood RE scheme will have little impact in the City. Commercial
premises will not be covered by Flood RE therefore if flood risk increases as a result of
climate change, commercial properties within the City Flood Risk Area may be
affected by market pressures for insurance cover. This could particularly affect SMEs.
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The City Corporation regularly reviews its approach to issues which present a
potential risk to the City. Flood risk is one of the issues on the City Corporation‘s
Strategic Risk Register and is reviewed in the light of emerging information such as
climate change projections. Monitoring of the implementation of this LFRMS will
inform the periodic reviews of risk.
What we will do
Continue to monitor the progress of the Flood RE proposals and assess their
impact on the City
Continue to assess flood risk for the City Corporation‘s strategic risk register in
the light of emerging information.
4.2.4 SuDS approvals
The City of London Corporation as the Lead Local Flood Authority for the City of
London has a duty to develop a Sustainable Drainage Approval Body (SAB) to
approve all non-exempt building proposals. This approval will be required before
construction can commence and will run in parallel with planning approval for any
application placed before it. The approvals should be in accordance with the
National Standards for Sustainable Drainage.
The SAB was scheduled to be operational from 1 April 2014 but has now been
delayed as the Government is refining the proposed procedures and related
National Standards and has yet to lay the required secondary legislation before
Parliament.
What we will do
Continue to develop the necessary SAB processes within the City Corporation
to fulfil this obligation within the timeframe laid down by Government
4.2.5 Asset register
The Corporation has an obligation under the Flood and Water Management Act
2010 to establish and maintain a register of structures or features which, in the
opinion of the authority, are likely to have a significant effect on a flood risk in its
area. Given the nature and size of the City there are limited features that could be
classified as such. Those identified are the highway gullies and the river defences
including those buildings that act as a defence against river flooding.
What we will do
• The City Corporation has implemented a dynamic Highway Management
System (HyMS). This will include information on assets which have an impact
on flood risk. Public access to this register will be made available through the
City of London web site.
• Update the condition and state of repair of the flood risk assets on HyMS
incorporating Environment Agency data on river flood defence walls
annually.
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4.2.6 Flood investigation
The City Corporation has an obligation under the Flood and Water Management
Act to carry out investigation of reported flooding incidents. Flooding incidents are
generally reported through the Contact Centre who will pass the report to the
Drainage Section of the Highways & Cleansing Division. An officer will then
investigate the incident and record the information. Where there are multiple
properties affected by flooding from a single source the officer will record the
information, investigate the cause and produce a report.
What we will do
• Continue to maintain the register of flooding incidents
• Produce flood investigation reports for instances of multiple property flooding from
a single source
4.2.7 Warning and Informing
The City Corporation‘s Security and Contingency Planning team is able to assist City
businesses with the development and exercising of their business continuity and
emergency plans. Further information about accessing this support can be found
on the City Corporation‘s website‘s business continuity pages.
The City Corporation is a Category 1 responder under the Civil Contingencies Act
and is responsible for warning and informing the public. Public information provision
will be undertaken in accordance with the Emergency Preparedness and
―Expectations and Indicators of Good Practice Set for Category 1 and 2
Responders”.
Live flood warning is available through the Environment Agency for river and
groundwater flooding and research is currently progressing to enable rapid
forecasting of urban flooding from manholes and other sewerage nodes. In the
event of an emergency, the City Corporation will work together with other agencies
including the emergency services and neighbouring Local Authorities to respond as
set out within the Multi Agency Flood Plan and the City‘s Emergency Management
Plan.
Consideration of the needs of all the City‘s communities has been taken into
account in preparation of the Multi Agency Flood Plan and the City‘s Emergency
Management Plan. The City will adopt an inclusive approach to warning and
informing paying particular attention to those who may be more vulnerable during
flooding events.
What we will do
Continue to support the City‘s businesses and residents by warning and
informing them of flood risks and supporting business continuity and
emergency plans
Work with the City Property Association and other business and resident
associations, as appropriate, to raise awareness of flood risk amongst their
members
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Encourage businesses and communities that are at risk of flooding to use the
Environment Agency‘s flood warning service for river and groundwater
flooding and any future flood warning system for surface water / sewer
flooding.
4.2.8 Site Specific Flood Risk Management Plans
The Flood Risk Regulations 2009(regulation 26) requires that LLFAS prepare a flood risk
management plan in relation to each relevant flood risk area. Virtually the whole of
London has been identified as a flood risk area under these regulations. For this
cycle of plans Lead Local Flood Authorities (LLFAs) need to prepare Flood Risk
Management Plans (FRMP)that cover local sources of flooding (i.e. from surface
water, groundwater and ordinary watercourses) for Flood Risk Areas. The
Environment Agency needs to prepare FRMPs for main rivers, the sea and reservoirs
in England. The Environment Agency and LLFAs can develop separate plans if they
wish. However the City has opted to prepare a FRMP jointly with the Environment
Agency and other LLFAs. To do this we will feed in the actions identified in this Local
Flood Risk Management Strategy which include actions to manage flood risk in the
areas identified as being at specific risk: Farringdon Street, Paul‘s Walk and Victoria
Embankment. The City Corporation will prepare specific flood risk management
plans for these areas as a key action in the Environment Agency‘s strategic Thames
River Basin District Flood Risk Management Plan.
What we will do
Prepare and implement site specific flood risk management plans for
Farringdon Street, Paul‘s Walk and Victoria Embankment seeking contributions
from beneficiaries of any area-wide flood alleviation measures
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4.3 Objective 3: Emergency response to flooding
To respond effectively in the event of flooding providing emergency assistance to
those in need
The City Corporation has Emergency Response plans in place. These plans include
the Multi Agency Flood Plan, the Emergency Management Manual and Rest Centre
Plans for those evacuated from their homes.
The Multi Agency Flood Plan (MAFP) An agreed framework between
category 1 and 2 responders which sets out a co-ordinated response and
recovery phase to severe flooding in the City of London.
The Emergency Management Manual is a plan used by the City Corporation
to respond to major incidents within the City.
The City Corporation also has a Rest Centre Plan which details how the Local
Authority could care for those evacuated from their homes due to an
incident. The City Corporation has plans for Rest Centres in more than one
location within the City.
Local Authorities can be contacted 24/7 to initiate a response capability.
The contact numbers for the City Corporation (daytime hours) are 020 7332
3417/1969/3584 and 3914.
Out of hours the City Corporation can be reached on 020 7606 3030.
What we will do:
Ensure that emergency arrangements and plans are in place to respond to
major incidents
Embed the current MAFP by training and exercising it with appropriate
partners.
Review and update the MAFP every five years or more frequently if
circumstances require.
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4.4 Objective 4: Recovery from flooding
To assist in recovery enabling the City residents and businesses to resume normal
activities promptly
The City Corporation intends to reduce the impact of flooding in the City and to
create a model of best practice for dealing with flood risks for owners of commercial
property and critical infrastructure.
The City Corporation has local plans and London has regional plans in place to assist
businesses and residents with the return to normality.
During the latter stages of a major flooding incident (the recovery period and return
to normality) the City Corporation may be able to provide services and staff to assist
with the following resources drawn from day to day operations such as;
Technical and Engineering Advice
Building control
Highways services
Public health and environmental issues
Provision of reception centres
Re-housing and accommodation needs
Transport
Psychosocial support
Help lines
Welfare and financial needs
Depending on the severity of the flooding, the City Corporation may decide to
establish a Community Assistance Centre to undertake a detailed Community
Impact Assessment, to provide advice and support to affected people and to
support the recovery of the community in a local setting.
The City Corporation may also decide to establish a Business Information Centre
(BIC), to undertake a Business Impact Assessment, to provide advice and support to
affected businesses and to support the recovery of the City‘s business community.
Specialist advice may need to be sought to address damage to historic structures.
Where multiple properties are affected by a single source of flooding, the City
Corporation will investigate the causes and impact of flooding and prepare a report
outlining any actions to reduce the risk of reoccurrence.
What we will do:
Ensure that recovery arrangements and plans are in place to deal with flood
recovery.
24
4.5 Objective 5: Partnership working
To engage with other flood risk management authorities taking action to reduce
flood risk through partnership working within and beyond the City‘s boundaries
Flooding does not respect local authority boundaries therefore it is essential that
Lead Local Flood Authorities work in partnership across local authority boundaries
and with a range of agencies to build up a comprehensive picture of the flood risks
and actions to reduce that risk. Local actions will form part of a wider strategy for
reducing flood risk in the Thames River Basin, integrating cross boundary actions for
effective flood risk management.
The Flood and Water Management Act (2010) gives local authorities the lead in
managing local flood risk and has designated the City Corporation as the Lead
Local Flood Authority (LLFA) for the City of London. This role requires partnership with
all relevant bodies to help manage flood risk in the area.
The ‗duty to cooperate‘ is a statutory requirement in the Localism Act 2011, which
amends the Planning and Compulsory Purchase Act 2004. It places a legal duty on
local planning authorities, county councils in England and public bodies to engage
constructively, actively and on an on-going basis to maximise the effectiveness of
Local and Marine Plan preparation relating to strategic cross boundary matters.
4.5.1 Drain London
In order to fulfil these roles the City Corporation works in partnership with a wide
range of other organisations including the Environment Agency, Thames Water, the
emergency services, Transport for London (TfL) and multiple utility infrastructure
providers, such as UK Power Networks and BT. Partnership working with other London
boroughs and the GLA has been established through membership of the Drain
London Forum. This partnership group was established by the Greater London
Authority (GLA) to bring together the GLA, the London boroughs and the City of
London, the Environment Agency, Thames Water, Transport for London and London
Councils to address surface water flooding issues. The Drain London Forum assists
boroughs with their responsibilities for managing flood risk by sharing good practice,
knowledge and expertise.
4.5.2 Environment Agency
Partnership working with the Environment Agency (EA) covers a number of different
aspects including assistance in fulfilling the requirements of the Flood Risk
Regulations 2009. Through this partnership the City Corporation completed and
published a Preliminary Flood Risk Assessment, funded through Drain London in
December 2011. In December 2013 the Environment Agency published
comprehensive flood mapping covering all sources of flooding. The City Corporation
provided additional modelling for the Environment Agency‘s published maps to
ensure that the most accurate and consistent picture of flood risk is presented.
Future collaboration with the EA will include preparation of the Thames River Basin
District - Flood Risk Management Plan which will cover London‘s identified Flood Risk
Area. This plan will be subject to public consultation and will be published by
December 2015.
25
The Environment Agency is also the lead organisation co-ordinating the Thames
Estuary 2100 Project. The Thames Estuary 2100 plan (TE 2100 plan) identifies mitigation
that will reduce the City‘s vulnerability to river flood risk from the River Thames and its
tidal influences. The City Corporation has a role in ensuring the delivery of local
TE2100 actions which include flood defence maintenance and the raising the flood
defences along the riverside by up to 0.5 metres by 2065 and a further 0.5metres by
2100. Further protection will result from wider actions such as allowing sacrificial
water storage in flood plain areas elsewhere in the Thames Estuary during periods of
heavy rainfall.
The Environment Agency (EA) co-ordinates the funding of flood mitigation projects
through the Flood and Coastal Erosion Risk Management Grant-in-Aid (FCRM GiA).
The costs of each scheme are balanced against the value of the benefits that the
scheme would bring in order to allocate funding in the most cost effective manner.
Assessment of a series of possible actions to alleviate flood risk in Farringdon Street
and Paul‘s Walk on the Thames Riverside found that major engineering projects
would be very expensive and difficult to deliver, would not offer cost effective
solutions and concluded that flood resistance and resilience measures in the
immediate area provides the most cost effective option for protecting businesses
from flooding. Co-operation will continue to explore possible EA funding to reduce
flood risk in the City.
4.5.3 Port of London Authority
The Port of London Authority works to ensure navigational safety along the tidal
Thames, promote use of the river and safeguard its unique marine environment. It
works in partnership with people looking to use the river whether for trade, travel,
recreation or pleasure. The City Corporation will work in partnership with the Port of
London Authority to ensure that flood risk is taken into account in consideration of
development associated with the River Thames.
4.5.4 Neighbouring boroughs
More detailed flood risk planning is carried out with the members of the Central
London North Partnership Group which comprises the boroughs that form the
catchment areas that affects the City‘s flood risk: Islington, Camden, Westminster,
Kensington & Chelsea and Hammersmith & Fulham. Liaison with Tower Hamlets and
Newham, which are the receiving LLFAs for the City‘s surface water drainage and
sewers, is also essential. The Central London North Partnership Group also includes
representatives from other Risk Management Authorities such as the Environment
Agency, Thames Water, and Transport for London.
The City Corporation commissioned research into possible mitigation measures
which could reduce the risk of surface water and sewer flooding. Initial assessments
carried out according to the partnership funding process set out by Defra, identified
that local mitigation projects would be ineffective in preventing flooding. Projects
would need to cover the wider catchment which encompasses much of Camden
to the north and extends into Westminster, Kensington and Chelsea and
Hammersmith and Fulham to the west. Alleviation of flooding in the City‘s flood risk
hotspots would require extensive retrofitting of Sustainable Drainage Systems (SuDS)
in these areas. The schemes as they stand did not achieve a high enough
partnership funding score to attract Defra funding, therefore although schemes may
26
be effective in reducing flood risk substantial local funding would be required from
the beneficiaries of the flood alleviation projects.
The City will continue to pursue the incorporation of SuDS into new and existing
buildings within the City and in these wider catchment areas. Neighbouring
boroughs, the GLA, Thames Water and the Environment Agency will be key partners
in progressing this action. Section 13 of the Flood and Water Management Act 2010
imposes a duty on risk management authorities to co-operate with other relevant
authorities in the exercise of their flood risk management functions.
In relation to individual developments in a neighbouring borough, where the
relevant SuDS approval body believes a road in the City will be affected it will have
a duty consult the City, in the City‘s role as highways authority.
4.5.5 Regional Flood and Coastal Committee
The Regional Flood and Coastal Committee (RFCC) is a committee established by
the Environment Agency under the Flood and Water Management Act 2010 that
brings together members appointed by Lead Local Flood Authorities (LLFAs) and
independent members with relevant experience, to discuss flood and coastal risk
management work in their region. The City‘s RFCC Member also represents the
neighbouring boroughs of the Central North London Partnership Group.
4.5.6 Utility providers
Thames Water is an important partner in the implementation of flood mitigation and
resistance measures. Thames Water has a remit through the utilities regulator OFWAT
to reduce the number of properties affected by sewer flooding. OFWAT impose strict
criteria and will only fund projects where there is a history of internal sewer flooding
of premises during 1 in 10 year rainfall events. Although not strictly a flood risk
mitigation project the proposed Thames Tideway Tunnel Project will intercept
combined sewer outflow pipes and prevent them from discharging sewage into the
Thames during heavy rain storms. In parallel with this Thames Water is promoting the
use of Sustainable Drainage (SuDS) to reduce the rate and quantity of surface water
run-off into London‘s combined sewerage network.
Other utility providers will need to be kept up to date with the flood risks affecting
their networks. Flood risk strategies provide an opportunity for engagement with
these organisations
4.5.7 Transport providers
Transport providers have their own flood risk plans covering emergency response to
flooding incidents and asset resilience in the face of climate change. Transport for
London is carrying out a comprehensive Flood Risk Review Assessment for London
Underground, and Thameslink is carrying out a review of the vulnerability of existing
assets on their network.
The City could be affected by disruption to transport networks across a wide
geographical area since around 90% of journeys to work in the City are made by
public transport.
27
The City Corporation will continue to engage with transport providers to gain a
better understanding of the risks associated with flooding on the transport network
and measures to mitigate the impact of flooding.
4.5.8 Technical bodies and Associations
London Drainage Engineering Group (LoDEG), Association of Thames Drainage
Agencies (ATDA) and Construction Industry Research and Information Association
(CIRIA) provide technical support and training related to flood risk and SuDS.
The City Property Association, which represents the interests of commercial property
owners and major occupiers in the City will work with the City to raise awareness of
flood risks including the likely disruption and insurance implications of widespread
flooding across London.
4.5.9 Emergency Services
In the event of an emergency, the City will work together with other agencies
including the emergency services and neighbouring Local Authorities to respond as
set out within the Multi Agency Flood Plan and the City‘s Emergency Management
Plan.
What we will do:
Work through Drain London to contribute to a coherent London wide
approach to flood risk
Work with the Central London North Flood Risk Partnership Group to ensure
that appropriate policies are included in our partner‘s Flood Risk Strategies
and Local Plans
Work with the Environment Agency to implement the City‘s actions from the
TE 2100 Plan and the requirements of the Flood Risk Regulations
Continue to discuss possible funding of local projects with the Environment
Agency
Engage with and make representations to Thames Water and OFWAT to
progress widespread retrofitting of SuDS into existing properties through the
Thames Water draft five year plan consultation process
Work with utility providers to build resistance and resilience to flood risk
ensuring prompt recovery following a flood incident
Work with transport providers to ensure implementation of flood resilience for
transport networks
Work with technical bodies to provide technical guidance and training to
increase awareness of flood risk and mitigation.
Work with emergency services to provide effective response to flooding
incidents.
28
5 Actions to reduce flood risk in the City Signpost to the Flood and Water Management Act 2010 Section 9 (4) requirements
This section deals with
(d) the measures proposed to achieve the objectives,
(e) how and when the measures are expected to be implemented,
(f) the costs and benefits of those measures, and how they are to be paid for,
5.1 Measures to achieve objectives
The measures to be implemented to achieve the objectives will consist of a
combination of local actions through the spatial planning and development
management functions, SuDS approvals, flood investigation and promotion of
business and continuity awareness, complemented by wider actions in partnership
with other flood risk management bodies.
5.2 Site Specific Flood Risk Management Plans
The Flood Risk Regulations 2009 require that Lead Local Flood Authorities prepare
Flood Risk Management Plans (FRMP) for identified Flood Risk Areas by December
2015. These Flood Risk Areas are defined at a wide scale such that virtually the whole
of London is defined as a Flood Risk Area. The City has opted to prepare a FRMP
jointly with the Environment Agency and other LLFAs covering the Thames River Basin
District which includes the whole of London‘s Flood Risk Area. This wider catchment
FRMP will incorporate the actions identified in this strategy to manage flood risk in
the City‘s surface water flooding hotspots.
The City Corporation intends to prepare Flood Risk Management Plans for these
three areas by December 2015.
Farringdon Street & New Bridge Street
Paul‘s Walk
Victoria Embankment
29
Figure 8: Flood Risk Areas – England
5.3 Funding & Resources
Funding and resources to implement this strategy will come from a number of
different sources.
As LLFA the City Corporation is responsible for co-ordination and co-
operation with other risk management authorities to address flood risk in
the City and in this role will use existing resources to fulfil many of the
actions identified in the action plan.
In addition to this, grant funding may be available from sources such as
the Drain London fund which is managed by the GLA and the flood and
coastal erosion risk management Grant in Aid (FCRM GiA) which is
administered by the Environment Agency on behalf of Defra.
Thames Water is responsible for the upgrading of sewerage infrastructure
to prevent sewer flooding and to take account of future climate
predictions.
Utility companies and property owners are responsible for site specific
flood risk alleviation, resistance and resilience of their premises. Where
premises will benefit from wider flood alleviation schemes property
30
owners will be encouraged to provide a contribution towards such
schemes.
City developers are responsible for ensuring that flood risks are
addressed in building design and associated landscaping.
Resourcing considerations will need to include direct project funding, staff resources,
expert consultancy requirements and training needs to implement the Flood Risk
Action Plan.
5.4 Flood Risk Action Plan
Objective 1: Up to date information on flood risk
Action Who When Resources Funding
We will review the City
of London SFRA at
least every 5 years or
more frequently if
evidence suggests
that this is necessary.
This frequency of
review will enable the
impacts of climate
change to be taken
into account as
evidence emerges.
Built
Environment-
Planning
2017 City
Corporation
Consultancy
expertise
City Fund
revenue
budget
We will keep under
review the SFRAs and
flood risk modelling
that is carried out for
neighbouring
boroughs through the
Central London North
Flood Risk Partnership
Group
Built
Environment
Planning
Drainage
Annually City
Corporation
Neighbouring
LLFAs
City Fund
revenue
budget
We will provide the
most up to date
mapping and
modelling to the EA
for incorporation in
future reviews of the
FMfSW
Built
Environment
Planning
2013 to be
reviewed by
2019
City
Corporation
Consultancy
expertise
City Fund
revenue
budget
City Corporation as
LLFA will continue to
engage with other risk
management
authorities and other
interested parties to
Built
Environment
Other risk
management
authorities
Ongoing City
Corporation
Other
interested
City fund
revenue
budget
Other parties
31
improve data on
flood risk for the City
and
interested
parties
parties funding
Objective 2: To reduce vulnerability and cost of flood risk
Action Who When Resources Funding
Apply the National
Planning Policy
Framework (NPPF) and
National Planning
Practice Guidance
on flood risk,
developing and
implementing flood
risk policy in the Local
Plan which accords
with the Sequential
and Exceptions Tests.
Built
Environment
Planning
On-going City
Corporation
Developers
Environment
Agency
City Fund
revenue
budget
Implement planning
policy to avoid the
development of
vulnerable uses in the
City Flood Risk Area as
defined on the City of
London Local Plan
Policies Map
Built
Environment
Planning
On-going City
Corporation
Developers
Environment
Agency
City Fund
revenue
budget
Require the use of
green roofs and green
walls and other urban
drainage techniques
in new development
and encourage in
existing buildings to
improve flood
resilience subject to
impacts on heritage
value
Built
Environment
Planning
Town Clerks
On-going City
Corporation
Developers
City Fund
revenue
budget
Highlight the need for
future raising of flood
Built
Environment
2013- 2065 City City Fund
revenue
32
Action Who When Resources Funding
defences along the
riverside to developers
of property in this area
encouraging a
strategic approach to
local flood defences.
Planning Corporation
Environment
Agency
budget
Use pre-application
meetings to promote
flood resistance and
resilience measures to
property owners
considering
refurbishment or
redevelopment in the
City Flood Risk Area.
Built
Environment
Planning
On-going City
Corporation
City Fund –
revenue
budget
Promote flood
resistance and
resilience measures to
property owners in the
City Flood Risk Area
ensuring that the
heritage implications
of mitigation measures
are taken into
account.
Town Clerks 2013-14 City
Corporation
Drain London
Drain London
Funding
Local services
support grant
- Defra
Work to ensure all City
Corporation
infrastructure is
resistant and resilient
to flood risk, such as
the Waste Transfer
Station at Walbrook
Wharf
Town Clerks
Built
Environment
Highways &
Cleansing
City
Surveyors
On-going City
Corporation
City Fund
revenue
budget
Capital
budget for
resilience
improvements
Seek funding
contributions from
those who will benefit
from any collective
flood resistance and
resilience measures
Town Clerks
City
Surveyors
On-going City
Corporation
Beneficiaries
of resistance
and resilience
measures
Continue to monitor
the progress of the
Flood RE proposals
and assess their
Town Clerks
Built
2013-2025 City
Corporation
City Fund
revenue
budget
33
Action Who When Resources Funding
impact on the City Environment
Continue to assess
flood risk for the City‘s
risk register in the light
of emerging
information.
Built
Environment
Annually City
Corporation
City Fund
revenue
budget
Continue to develop
the necessary SAB
processes within the
City Corporation to
fulfil this obligation
within the timeframe
laid down by
Government
Built
Environment
2014/15 City
Corporation
Additional
staff and
training
required
City Fund
revenue
budget
SAB
application
fees
The City Corporation
has implemented a
dynamic Highway
Management System
(HyMS). This will
include information on
assets which have an
impact on flood risk.
Public access to this
register will be made
available through the
City of London web
site
Built
Environment
Highways &
Cleansing
On-going City
Corporation
Environment
Agency
City Fund
revenue
budget
Update the condition
and state of repair of
the flood risk assets on
HyMS incorporating
Environment Agency
data on river flood
defence walls
annually.
Built
Environment
Highways &
Cleansing
On-going City
Corporation
Environment
Agency
City Fund
revenue
budget
Continue to maintain
the register of flooding
incidents
Built
Environment
Highways &
Cleansing
On-going City
Corporation
City Fund
revenue
budget
Produce flood
investigation reports
for instances of
multiple property
Built
Environment
Highways &
On-going City
Corporation
City Fund
revenue
budget
34
Action Who When Resources Funding
flooding from a single
source
Cleansing
Continue to support
the City‘s businesses
and residents by
warning and informing
them of flood risks and
supporting business
continuity and
emergency plans
Town Clerks
Security and
Contingency
Planning
City Property
Association
On-going City
Corporation
City Fund
revenue
budget
Work with the City
Property Association
and other business
and resident
associations, as
appropriate, to raise
awareness of flood risk
amongst their
members
City Property
Association
City
Businesses
City
residents
On-going City
Corporation
City
businesses
City fund
revenue
budget
Encourage businesses
and communities that
are at risk of flooding
to use the
Environment Agency‘s
flood warning service
for river and
groundwater flooding
and any future flood
warning system for
surface water / sewer
flooding.
Environment
Agency
City
Businesses
City
residents
On-going Environment
Agency
City
Corporation
City
Businesses
Environment
Agency
funding
City
businesses
Prepare and
implement site
specific flood risk
management plans
for Farringdon Street,
Paul‘s Walk and
Victoria Embankment
seeking contributions
from beneficiaries of
any area-wide flood
alleviation measures
Town Clerks
Built
Environment
Security &
Contingency
Planning
2014/15 City
Corporation,
Neighbouring
boroughs,
Thames
Water,
Environment
Agency, GLA
City Fund
revenue
budget
Potential
grant funding
35
Objective 3: Emergency response to flooding
Action Who When Resources Funding
Ensure that
emergency
arrangements and
plans are in place to
respond to major
incidents
Security and
Contingency
Planning
On-going City
Corporation,
Emergency
Services,
Environment
Agency, City
businesses
and residents
City Fund
revenue
budget
Other
organisations‘
funds
Embed the current
MAFP by training and
exercising it with
appropriate partners.
Security and
Contingency
Planning
On- going City
Corporation,
Emergency
Services,
Environment
Agency, City
businesses
and residents
City Fund
revenue
budget
Review and update
the MAFP every five
years or more
frequently if
circumstances require
this.
Security and
Contingency
Planning
2017 City
Corporation,
Emergency
Services,
Environment
Agency, City
businesses
and residents
City Fund
revenue
budget
Objective 4: Recovery following flooding
Action Who When Resources Funding
Ensure that recovery
arrangements and
plans are in place to
deal with flood
recovery.
Security and
Contingency
Planning
On-going City
Corporation,
Emergency
Services,
Environment
Agency,
building
owners
City Fund
revenue
budget
Other
organisations‘
funds
Objective 5: Engagement with other flood risk management authorities
36
Action Who When Resources Funding
Work through Drain
London to contribute
to a coherent London
wide approach to
flood risk
Built
Environment
Planning &
Drainage
On-going City
Corporation,
GLA
City Fund
revenue
budget
Other
organisations‘
funds
Work with the Central
London North Flood
Risk Partnership Group
to ensure that
appropriate policies
are included in our
partner‘s Flood Risk
Strategies and Local
Plans
Built
Environment
Planning &
Drainage
On-going City
Corporation
North London
Central
Partnership
Group
Other Risk
Management
Authorities
RFCC
Member
City Fund
revenue
budget
Other
organisations‘
funds
Work with the
Environment Agency
to implement the
City‘s actions from the
TE 2100 Plan and the
requirements of the
Flood Risk Regulations
Town Clerks Short term
2010 to 2035
Medium
term 2035 to
2050
Long term
2050 to 2100
City
Corporation
Environment
Agency
City Fund
revenue
budget
Other
organisations‘
funds
Continue to discuss
possible funding of
local projects with the
Environment Agency
Built
Environment
Short term
2010 to 2015
City
Corporation
Environment
Agency
City Fund
revenue
budget
Environment
Agency funds
Engage with Thames
Water and OFWAT to
progress widespread
retrofitting of SuDS into
existing properties
through the Thames
Water draft twenty
five year plan
consultation process
Built
Environment
Consultation
on plan for
2015 to 2040
City
Corporation
Thames
Water
City Fund
revenue
budget
Thames Water
funding
37
Action Who When Resources Funding
Work with utility
providers to build
resistance and
resilience to flood risk
ensuring prompt
recovery following a
flood incident
Town Clerks
Built
Environment
On-going City
Corporation,
Utility
Providers,
Building
owners
City Fund
revenue
budget
Utility
providers
funding
Work with transport
providers to ensure
implementation of
flood resilience for
transport networks
Town Clerks
Built
Environment
Transport for
London
On-going City
Corporation
Transport
providers
City Fund
revenue
budget
Transport
provider
funding
Work with technical
bodies to provide
technical guidance
and training to
increase awareness of
flood risk and
mitigation.
Town Clerks
Built
Environment
On-going City
Corporation
Technical
bodies
City fund
revenue
budget
Work with emergency
services to provide
effective response to
flooding incidents
Security and
Contingency
Planning
On-going City
Corporation
Emergency
services
City fund
revenue
budget
38
6 Strategy review Signpost to the Flood and Water Management Act 2010 Section 9 (4) requirements
This section deals with:
(h) how and when the strategy is to be reviewed,
6.1 Public Consultation
The draft Local Flood Risk Management Strategy was subject to public consultation
in April 2014 in line with the requirements of the City Corporation‘s Statement of
Community Involvement.
6.2 Approval process
The Local Flood Risk Management Strategy was adopted by the Planning and
Transportation Committee on 23rd Sept 2014.
6.3 Governance and monitoring
Implementation of the Strategy will be overseen by the officer led Flood Risk Steering
Group. The Flood Risk Steering Group is chaired by the City Corporation‘s Director of
the Built Environment and includes representatives from Built Environment, City
Surveyors, Contingency Planning, and Town Clerks.
6.4 Review
The Strategy will be reviewed by the Planning & Transportation Committee every five
years alongside the City of London‘s Strategic Flood Risk Assessment.
39
7 Wider sustainability objectives Signpost to the Flood and Water Management Act 2010 Section 9 (4) requirements
This section deals with
(i)how the strategy contributes to the achievement of wider environmental
objectives
7.1 Strategic Environmental Assessment
The City of London draft Local Flood Risk Management Strategy has been subject to
Strategic Environmental Assessment (SEA) which evaluates the impact that the
strategy will have on wider sustainability objectives. Strategic Environmental
Assessment (SEA) is the process by which strategic plans and programmes are
assessed to ensure that they take account of social, environmental and economic
objectives for the area, fulfilling the requirements of the Strategic Environmental
Assessment (2001/EC/42) (SEA Directive). SEA was used during the preparation of the
strategy to evaluate options for achieving the flood risk objectives against a series of
wider sustainability objectives.
The sustainability objectives relevant to the Flood Risk Management Strategy were
determined at the SEA scoping stage which included consultation with the
Environment Agency, English Heritage, Natural England, GLA and flood risk
partnership group members.
The sustainability objectives relevant to the Local Flood Risk Management Strategy
are as follows:
1. To protect the health, wellbeing and safety of workers, residents and visitors
2. To protect property and essential infrastructure
3. To protect the historic environment, archaeological heritage and landscape
4. To protect and enhance biodiversity
5. To protect water quality and resources
6. To adapt to the impacts of climate change
7. To minimise adverse impacts on the economy
The impact of the flood risk strategy options was assessed against these wider
sustainability objectives taking account of the positive, negative and neutral
impacts, and the geographic scale and timescale of the impact (short, medium or
long term). Comments are included to highlight the significant effects of the
preferred options in terms of direct or indirect effects, whether effects are
permanent or temporary and whether there are likely to be cumulative effects.
The conclusions of the SEA are reported in the Strategic Environmental Assessment
Report and are summarised below:
40
SEA Objective 1: To protect the health, wellbeing and safety of workers, residents
and visitors.
Assessment of options against each of the Flood Risk Strategy objectives indicates
that a positive proactive approach will bring benefits in relation to the protection of
the health, wellbeing and safety of workers, residents and visitors. The greatest
danger to health is from sewer flooding which is influenced by actions in a wide
catchment area beyond the City. Therefore partnership working particularly on SuDS
implementation in neighbouring boroughs is a key activity to protect the health
wellbeing and safety of workers, residents and visitors.
SEA Objective 2: To protect property and essential infrastructure
A proactive approach, making sure that flood risk information is up to date and
local measures are implemented to enhance resistance and resilience to flooding,
will provide the best opportunities for protection of property and essential
infrastructure. The SEA identifies that the adoption of a co-ordinated approach to
flood investigation, flood risk asset management and emergency planning are
important elements for property protection.
SEA Objective 3: To protect the historic environment and archaeological heritage
The SEA assessment identifies that the most effective actions to protect historic assets
against flood risk include promotion of resistance and resilience measures warning
and informing and the preparation of co-ordinated management plans and
emergency and contingency plans for areas that are at risk of flooding. A lack of
partnership working beyond the city‘s boundaries could present greater risks to
historic assets by increasing the risk of surface water flooding exacerbated by
actions in neighbouring boroughs.
SEA Objective 4: To protect and enhance biodiversity
The register of flood risk assets where maintenance and state of repair are recorded
in one place presents opportunities for the protection and enhancement of
biodiversity particularly associated with the river defence flood walls which provide
important habitats along the river Thames area of metropolitan importance for
nature conservation. Partnership working is identified as important in protection and
enhancement of biodiversity since it will enable input from organisations with varied
expertise, for example the Environment Agency and the Port of London Authority, in
ensuring that flood risk management plans take account of biodiversity.
SEA Objective 5: To protect water quality and resources
The development of an effective SuDS approvals process will be important in
protecting water quality and resources through the impact of SuDS in reducing
rainwater run-off and preventing sewer overflows and also in conserving water by
collecting it for landscape watering etc. The preparation of co-ordinated plans for
flood risk areas and flood recovery will also assist in avoiding water pollution and
making the best use of water resources.
SEA Objective 6: Climate Change Adaptation
The uncertainties related to climate change make it essential that review of the City
of London Strategic Flood Risk Assessment is carried out at regular intervals in order
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to identify where climate change is having an impact on flood risks. Similarly
partnership working is important to gain knowledge of how climate change is
affecting the sewer flooding catchment areas and how sea level rise is affecting the
flood risk from the Thames.
SEA Objective 7: Minimise impacts on the economy
The provision of accurate flood risk information and the preparation of co-ordinated
flood risk management and recovery plans will be the most useful aspects in
minimising impacts on the economy. Warning and informing will also form a crucial
activity in making sure that businesses in the flood risk areas are aware of the risks
and make appropriate contingency plans.
7.2 Overall SEA conclusion
The SEA has considered a ―Do Nothing‖ approach against a series of proposed
actions related to flood risk. The ―Do Nothing‖ option results in poorer outcomes
against each of the SEA objectives. Therefore a positive approach to flood risk
management is recommended.
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Appendix 1 Legislative context
Pitt Review
Flood risk planning has assumed a high profile due to the extreme flooding events of
summer 2007 and the subsequent Pitt Review ‗Learning Lessons from the 2007
Floods‘ which was published in Dec 2008. The recommendations of this report, along
with legislative changes, require that local authorities assume a new role in co-
ordination of measures to minimise flood risk in their areas. More recent national
flooding has placed greater emphasis on flood risk planning as the frequency of
extreme weather events increases.
The Flood Risk Regulations 2009 came into force on 10th Dec 2009. These regulations
transpose EC Directive 2007/60/EC assessment and management of flood risks and
impose new duties on the Environment Agency and local authorities, including the
City as a lead local flood authority to:
Prepare a preliminary flood risk assessment by June 2011, for publication by the
Environment Agency in December 2011, showing the probability of flooding
and consequences for human health, the environment, cultural heritage and
economic activity
Prepare flood risk maps and flood hazard maps by June 2013, for publication by
the Environment Agency in December 2013
Prepare a flood risk management plan for areas which are at significant risk of
flooding by June 2015, for publication by the Environment Agency in
December 2015
Flood and Water Management Act 2010 – received Royal Assent on 8th April 2010. It
gives local authorities new responsibilities as lead local flood authorities (LLFA):
Part 1 of the act requires all lead local flood authorities in England to:
Develop, maintain, apply, and monitor the application of, a strategy for local
flood risk from surface run off, groundwater and ordinary watercourses, in
their area. The strategy must at least set out who the risk management
authorities are in the area and their relevant functions, the authority‘s
objectives for managing flood risk, as well as proposed measures to deliver
the objectives, and timescales for implementation of the measures; how
those measures are to be paid for as well as their costs and benefits, how
and when the strategy will be reviewed, and how the strategy contributes to
the achievement of wider environmental objectives. The lead local flood
authority must consult affected risk management authorities and the public
about its strategy and provide guidance on the application of the strategy.
Investigate flooding incidents in its area and report on its findings.
Establish and maintain a register of structures or features which may
significantly affect flood risk in their area including information regarding
ownership and state of repair.
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Contribute to sustainable development in the discharge of its flood risk duties.
Assume the power to designate features with respect to flood risk and
subsequently to act as responsible authority for such features.
Part 2 of the act gives local authorities new duties as ―approving bodies‖ with regard
to drainage including:
Approving rainwater drainage systems before commencement of any
construction works which have drainage implications
Adopting and maintaining approved systems which affect more than one
property
Approval of surface water drainage systems prior to connection to public
sewers. (Automatic right of connection to public sewers is removed by this
Act).
Part 3 of the act provides legislative powers for:
Consolidation of legislation relating to flood risk including Water Industry Act
1991, the Water Resources Act 1991, the Land Drainage Act 1991, the
Reservoirs Act 1975, the Highways Act 1980 (so far as relevant to water), the
Environment Act 1995 (so far as relevant to water), the Public Health Act 1936
(so far as relevant to water) and the Coast Protection Act 1949.
Provision of funding by Parliament to pay for expenditure under the Act
As Lead Local Flood Authority, the City Corporation is responsible for preparing and
implementing a Flood Risk Management Strategy for the City. The Requirements of
the Flood and Water Management Act with respect to this Flood Risk Management
Strategy are set out in fig 9
Fig 9: Requirements of the Flood and Water Management Act 2010 Section 9 Local flood risk
management strategies: England
(1)A lead local flood authority for an area in England must develop, maintain, apply and monitor a
strategy for local flood risk management in its area (a ―local flood risk management strategy‖).
(2)In subsection (1) ―local flood risk‖ means flood risk from—
(a) surface runoff,
(b) groundwater, and
(c) ordinary watercourses.
(3)In subsection (2)(c) the reference to an ordinary watercourse includes a reference to a lake, pond or
other area of water which flows into an ordinary watercourse.
(4)The strategy must specify—
(a) the risk management authorities in the authority's area,
(b) the flood and coastal erosion risk management functions that may be exercised by those
authorities in relation to the area,
(c) the objectives for managing local flood risk (including any objectives included in the
authority's flood risk management plan prepared in accordance with the Flood Risk Regulations 2009),
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(d) the measures proposed to achieve those objectives,
(e) how and when the measures are expected to be implemented,
(f) the costs and benefits of those measures, and how they are to be paid for,
(g) the assessment of local flood risk for the purpose of the strategy,
(h) how and when the strategy is to be reviewed, and
(i) how the strategy contributes to the achievement of wider environmental objectives.
(5)The strategy must be consistent with the national flood and coastal erosion risk management
strategy for England under section 7.
(6)A lead local flood authority must consult the following about its local flood risk management
strategy—
(a) risk management authorities that may be affected by the strategy (including risk
management authorities in Wales), and
(b) the public.
(7)A lead local flood authority must publish a summary of its local flood risk management strategy
(including guidance about the availability of relevant information).
(8)A lead local flood authority may issue guidance about the application of the local flood risk
management strategy in its area.
(9)A lead local flood authority must have regard to any guidance issued by the Secretary of State
about—
(a) the local flood risk management strategy, and
(b) guidance under subsection (8).
This strategy will be subject to Strategic Environmental Assessment (SEA) as required
by the SEA Directive and will be reviewed by other stakeholders during a period of
public consultation prior to adoption.
Civil Contingencies Act 2004
Local Authorities have 7 duties under the Civil Contingencies Act 2004
To operate with other local responders to enhance coordination and
efficiency;
Ensure information is shared with local responders to enhance coordination:
Carry out risk assessments
Have emergency plans in place
Have business continuity management arrangements in place
Have arrangements in place to warn and inform the public in the event of an
Emergency
Provide advice and assistance to businesses and voluntary organisations
regarding business continuity management
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Planning Guidance
The National Planning Policy Framework (NPPF) was introduced in 2012 and provides
Government guidance on Planning. The Core Planning principles include the
following requirements
support the transition to a low carbon future in a changing climate, taking full
account of flood risk and coastal change, and encourage the reuse of
existing resources, including conversion of existing buildings, and encourage
the use of renewable resources (for example, by the development of
renewable energy)
promote mixed use developments, and encourage multiple benefits from the
use of land in urban and rural areas, recognising that some open land can
perform many functions (such as for wildlife, recreation, flood risk mitigation,
carbon storage, or food production)
Section 10 of the NPPF states that ―Local planning authorities should adopt
proactive strategies to mitigate and adapt to climate change, taking full account of
flood risk, coastal change and water supply and demand considerations.
National Planning Policy Framework requirements for development
Inappropriate development in areas at risk of flooding should be avoided by
directing development away from areas at highest risk, but where development is
necessary, making it safe without increasing flood risk elsewhere. Local Plans should
be supported by Strategic Flood Risk Assessment and develop policies to manage
flood risk from all sources, taking account of advice from the Environment Agency
and other relevant flood risk management bodies, such as lead local flood
authorities and internal drainage boards. Local Plans should apply a sequential, risk-
based approach to the location of development to avoid where possible flood risk
to people and property and manage any residual risk, taking account of the
impacts of climate change, by:
● applying the Sequential Test;
● if necessary, applying the Exception Test;
● safeguarding land from development that is required for current and future flood
management;
● using opportunities offered by new development to reduce the causes and
impacts of flooding; and
● where climate change is expected to increase flood risk so that some existing
development may not be sustainable in the long-term, seeking opportunities to
facilitate the relocation of development, including housing, to more sustainable
locations.
The NPPF is supported by National Planning Practice Guidance which provides
details of how the flood risk elements of the NPPF should be applied.
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Other City of London strategies and plans
The City Corporation has adopted a number of plans and strategies which are
relevant to this Flood Risk Management Strategy and these have been taken into
account in its preparation:
Sustainable Community Strategy
The City Together is a non-executive partnership that brings together the key public,
private and voluntary sector providers in the City with representatives from the City‘s
resident, business, worker and faith communities.
The City Together's role is to generate and pursue a collectively agreed long term
vision with strategic objectives for the City, designed to promote the economic,
social and environmental wellbeing of the City of London. The City Together also
aims to promote and encourage more effective partnership working and is
responsible for developing the City‘s Sustainable Community Strategy called 'The
City Together Strategy: The Heart of a World Class City'. Through The City Together,
our diverse communities and partners can work together to support the continued
success of the City in a way that meets the needs of our residents, businesses,
workers and visitors.
Climate change adaptation strategy
The City of London‘s Climate Change Adaptation Strategy (2010 update) uses the
latest UK Climate Projections, UKCP09 and builds on the impacts previously identified
in the London Climate Change Partnership‘s publication, ‗London‘s Warming‘1.
The climate change risks for the City are summarised below:
Hotter, drier summers,
Milder, wetter winters,
More frequent extreme high temperatures,
More frequent heavy downpours of rain,
Significant decreases in soil moisture content in summer,
Sea level rise and increases in storm surge height,
Possible higher wind speeds.
Longer periods when weather systems are locked into the same pattern
The City of London‘s Climate Change Adaptation Strategy, aims to identify the
priority risks associated with climate change and proposes adaptation measures
which are designed to ensure that the City‘s infrastructure and services cope under
a changing climate. The City Corporation will continue to review emerging
experience of climate change affecting south east England for its impacts on the
City.
Core Strategy/Local Plan
The City‘s adopted Core Strategy sets out the future vision and key polices for
planning the City of London. This will be replaced in 2015 by a new planning
strategy for the City of London called the Local Plan. The Plan sets out the vision for
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shaping the Square Mile in the future and contains the policies by which planning
decisions will be made.
The Core Strategy and emerging Local plan set out the City‘s approach to flood risk
associated with new development requiring flood risk assessments for any
development sites located in the City Flood Risk Area.
The Local Plan is accompanied by a Policies Map (in two parts) that shows where its
policies operate.
Multi Agency Flood Plan
The Multi Agency Flood Plan outlines the various responsibilities of different
organisation with regard to emergency and contingency planning for flood risk.
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Appendix 2 Flood Risk Powers and Responsibilities Signpost to the Flood and Water Management Act 2010 Section 9 (4) requirements
a) The risk management authorities in the authority‘s area and
b) The flood and coastal erosion risk management functions that may be exercised
by those authorities in relation to the area,
Risk Management Authorities and other interested parties
The Flood and Water Management Act 2010 recognises the following
authorities as risk management authorities:
Lead Local Flood Authorities (LLFA)
The Environment Agency
Water companies
Highways authorities
Internal Drainage Boards (not relevant to the City)
District and borough councils
These risk management authorities have a duty to co-operate with each other in the
exercise of their duties and the power to take on flood risk functions from other
authorities by mutual agreement.
The relevant risk management authorities for the City are the City Corporation as
LLFA for the square mile, the Environment Agency which exercises a national and
regional role in co-ordinating flood risk management, Thames Water as the water
company and sewerage undertaker for the City, and Transport for London as the
Highways Agency for parts of the City.
A number of other authorities, although not defined as risk management authorities,
have a role to play in the management of flood risk in the City. These include the
Greater London Authority (GLA) which manages the Drain London project,
improving information on flood risk for London; Network Rail which manages
mainline stations feeding the City; the Emergency Services and first responders in
tackling flooding incidents; the Marine Management Organisation and the Port of
London Authority; and neighbouring boroughs as LLFAs for their areas since they also
influence the City‘s flood risk management.
Risk management functions in the City
Authority Function Responsibilities
City
Corporation
Lead Local
Flood Authority
Strategic role in overseeing the management of
local flood risk i.e. flood risk from surface water
runoff, groundwater and ordinary watercourses.
This includes responsibility for
Preparing a Local Flood Risk Management
Strategy
Investigation of flooding incidents and
preparation of flood incident reports
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Authority Function Responsibilities
Maintaining register of assets that impact
on flood risk and registering appropriate
assets
Implementing SuDS Approval Body (SAB)
City
Corporation
Planning
Authority
Ensuring that development does not increase
vulnerability to flood risk for new and existing
properties
City
Corporation
Category 1
responder
under the Civil
Contingencies
Act
Ensuring that systems and processes are in place
to provide emergency response to flooding
City
Corporation
Highway
Authority
Duty to maintain the highway including
responsibility for drain and gully maintenance on
non-strategic roads in the City
Environment
Agency
Strategic Role Taking a strategic overview of the management
of all sources of flooding and coastal erosion. This
includes setting the direction for managing the
risks through strategic plans; providing evidence
and advice to inform government policy and
support others; working collaboratively to support
the development of risk management skills and
capacity and probvidin a framework to support
local delivery.
Environment
Agency
Operational role Operational responsibility for managing the risk of
flooding from main rivers, reservoirs, estuaries and
the sea, as well as being coastal erosion risk
management authority.
Responsible for inspection of flood defences and
maintenance of the Thames Barrier.
Advisory and statutory consultee role in the
assessment of flood risk associated with planning
policy and development.
Advisory role in assessment of Multi Agency Flood
Plans.
Thames
Water
Sewerage
undertaker
Responsible for provision and maintenance of the
sewer network
Upgrade of sewer network to facilitate increased
drainage capacity requirements
Responsible for implementation of Thames
Tideway Tunnel to reduce sewer outflows into the
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Authority Function Responsibilities
Thames
Transport for
London
Transport
infrastructure
provider
Responsible for provision and maintenance of
strategic road network and London Underground
and bus networks ensuring their resilience to flood
risk
Network Rail Transport
infrastructure
provider
Responsible for provision and maintenance of
railway network serving mainline stations in the
City and their resilience to flood risk
Greater
London
Authority
Drain London Facilitation of co-ordinated working on flood risk
across London including provision of guidance
and information
Neighbouring
boroughs
LLFA s for their
areas
Strategic role in overseeing the management of
local flood risk in their areas and liaison with other
LLFAs affected.
Businesses
and
Residents
Property owners
Responsible for flood resistance and resilience and
emergency and contingency planning
associated with properties
Riperian owners are responsible for the
maintenance of flood defences
Utility
companies
Utility providers Responsible for provision and maintenance of
utility infrastructure – electricity , gas
telecommunications etc. and ensuring its
resilience to flood risk
Glossary City Flood Risk Areas – Areas of the City that are at risk of river or surface water
flooding as defined in the City of London Local Plan
Drain London – Multi agency partnership co-ordinated by the Greater London
Authority to provide pan London information and advice on flood risk
Flood Zones – Environment Agency defined zones with varying probabilities of river
flooding
Flood Zone 1- Low probability of flooding - less than 1 in 1,000 annual
probability of river or sea flooding (<0.1%)
Flood Zone 2 – Medium probability of flooding - between a 1 in 100 and 1 in
1,000 annual probability of river flooding (1% – 0.1%)
Flood Zone 3 - High probability of flooding - a 1 in 100 or greater annual
probability of river flooding (>1%)
FMfSW – Flood Map for Surface Water – National scale maps published by the
Environment Agency showing surface water flood risk.
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LLFA - Lead Local Flood Authority – The local authority with the statutory responsibility
for flood risk management in its local area. The City Corporation is the LLFA for the
City of London geographic area.
LFRMS – Local Flood Risk Management Strategy – Strategy for managing flood risk at
a local level as required by the Flood and Water Management Act 2010
Multi Agency Flood Plan – Emergency Plan for responding to flooding
NPPF – National Planning Policy Framework – The government‘s statement of
planning guidance to local planning authorities, issued by the Department of
Communities and Local Government in March 2012. The City Corporation must take
account of it in preparing and implementing its planning policies.
Preliminary Flood Risk Assessment – preliminary assessment of the risk of flooding as
required by the Flood Risk Regulations 2009
Risk Management Authorities – authorities defined in the Flood and Water
Management Act as having flood risk responsibilities
Sequential Test and Exceptions Test – Tests to be applied to proposals for new
development in order to avoid allowing vulnerable uses in areas that are prone to
flooding. Details of these tests can be found in the National Planning Practice
Guidance to the National Planning Policy Framework SEA – Strategic Environmental
Assessment – assessment of the likely environmental, social and economic
assessment of the implementation of plans and programmes as required by the EU
Strategic Environmental Assessment Directive
SFRA – Strategic Flood Risk Assessment – comprehensive assessment of the risks of
flooding from all sources
Surface Water Management Plan – plan for the management of surface water to
reduce risk of flooding from this source.
TE2100 – Thames Estuary 2100 Plan – Environment Agency‘s plan for addressing flood
management in the Thames Estuary up to 2100
Contact: Janet Laban Tel: 020 7332 1148